Let be a Zoll manifold, i.e., a smooth, compact, Riemannian manifold without boundary all of whose geodesics are closed with a minimal common period . The positive definite Laplace-Beltrami operator has eigenvalues which cluster around for some sequence . This article is concerned with the number of in a window of fixed size around , denoted by When the set of trajectories with period smaller than has zero measure, there is , depending only on , such that as . However, for a general Zoll manifold this may not be the case. We show that, nevertheless, there is , independent of , such that as . In addition to asymptotics for the counting function, we study the kernel of the spectral projector for the Laplacian, onto the spectrum in . We show that for and in a shrinking neighborhood of a point with few loops of length smaller than , and its derivatives have the same asymptotics as those on the round sphere and flat torus.

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